There has always been a
lot of discussions as to wether it was possible or not to recover erased data
directly from the platters of crashed hard drives. Datarecovery companies have
often implied that they were able to achieve such a feat. The DoD recommendations
for secure wiping have given substance to the rumour. This article
by Science News seems to demonstrate that while some evidence gathering is possible,
we are still far from being able to recover data from hard drive tracks. Three
problems must be solved to achieve that recovery

imaging the hard drive
tracks - consider the recording density of a year 2000 40GB hard drive compared
to a simple tape.

recovering the corrupted,
damaged or erased tracks - when we consider erased data, add the challenge
of finding the "ghost" tracks(*) resulting from head positioning
imprecisions. Even if we assume these tracks can be found and be measured,
imagine the resulting mess a hard drive will be after dozens of write/erase
cycles.

rebuilding the data from
the image acquired in the first step requires a huge amount of processing
power, emulating the DSP of the target hard drive.

Then of course, the eventually
recovered data would probably be totally worthless. No one will go through the
above cycle to recover business data - this is just not cost effective. If,
for the sake of reasonning we admit you just have, would you run critical processes
on potentially flawed data ? The same holds for forensic analysis : except in
extremely high profile cases such as the Watergates tapes, that could act as
a catalyst, an incentive to drive the technology forward, one cannot imagine
that courts will be allowed to spend that many resources. And if they did, what
would be the values of the evidence recovered ? Small corruptions can completely
change the meaning of messages.... Finally, if a governmental agency had such
an ability, do you think they would let us know ?

(*) ghost tracks can probably
be recovered from floppies where tracks are roughly one tenth of a milimeter
wide and magnetic fields, compare that to the 20 Gigabit per square inch common
in Y2K's hard drives...